Justia Civil Rights Opinion Summaries

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law

Several healthcare employees in Colorado, including those at the University of Colorado Hospital Authority and South Denver Cardiology Associates, were terminated after refusing to comply with their employers’ COVID-19 vaccination mandates. These mandates, implemented in 2021, required employees to either be vaccinated or obtain a medical or religious exemption. The plaintiffs declined vaccination and did not seek exemptions, resulting in their dismissal.Following their terminations, the plaintiffs filed separate lawsuits in the United States District Court for the District of Colorado, asserting nearly identical claims. They alleged violations of statutory, constitutional, and contractual rights, including claims under 42 U.S.C. § 1983, state-law breach of contract and tort claims, and an implied private right of action under the Food, Drug, and Cosmetic Act. The defendants moved to dismiss on grounds such as sovereign immunity, qualified immunity, and failure to state a claim. The district courts dismissed all claims, finding that the plaintiffs had not adequately pled any viable legal theory. The courts also denied the plaintiffs’ requests to amend their complaints after judgment was entered.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissals de novo. The court held that none of the statutes cited by the plaintiffs—including the Emergency Use Authorization statute, the PREP Act, and 10 U.S.C. § 980—unambiguously conferred individual rights enforceable under § 1983. The court also found that the constitutional claims, including those based on due process and equal protection, were not adequately pled and that the breach of contract claim was waived for lack of argument. The Tenth Circuit affirmed the district courts’ judgments, holding that the plaintiffs failed to state any claim upon which relief could be granted and that the lower courts did not abuse their discretion in denying leave to amend. View "Timken v. South Denver Cardiology Associates" on Justia Law

A former employee of an Oklahoma-based aviation training company alleged that his one-year employment contract was not renewed because he is a disabled veteran and because he complained to human resources about his supervisor’s disparaging comments regarding his disability. The employee, a Marine veteran with a high VA disability rating, worked as a Loadmaster Instructor in Kuwait. During his tenure, he disclosed his disability status for affirmative action purposes and later informed his supervisor and a co-worker when his rating increased. After this disclosure, his supervisor made inappropriate remarks about the disability system and the employee’s status, which led to a complaint and a subsequent reprimand of the supervisor. The employee’s FAA flight certificate expired shortly before his contract ended, and he received a negative performance appraisal from his immediate supervisor. The company’s higher management, who were responsible for contract renewal decisions, cited subpar job performance and the lapse of the flight certificate as reasons for not renewing the contract.The United States District Court for the Western District of Oklahoma granted summary judgment to the employer on all claims. The court found that the employee failed to present sufficient evidence that the stated reasons for non-renewal were pretextual under the Americans with Disabilities Act (ADA) or that the decision was motivated by discriminatory or retaliatory animus. The court also held that the Uniformed Services Employment and Reemployment Rights Act (USERRA) does not protect against discrimination based solely on disability status, but rather on military service itself.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The appellate court held that the employee did not create a triable issue of fact under the “cat’s paw” theory linking a supervisor’s alleged bias to the ultimate decisionmakers. The court also confirmed that USERRA does not extend to claims of discrimination based solely on disability status. View "Sellman v. Aviation Training Consulting" on Justia Law

Bernard Mims spent a decade in prison after being convicted of murder, a conviction later vacated when the State’s Attorney’s Office lost confidence in the case for reasons unrelated to the claim at issue here. Mims then brought a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police detectives. He alleged, among other things, that two detectives violated his due process rights by failing to disclose an audio recording of a conversation between two individuals, one of whom had previously claimed involvement in the murder. Mims argued that this recording was exculpatory because it implicated someone else in the crime.The United States District Court for the Northern District of Illinois granted summary judgment to the defendants on all claims. As relevant to this appeal, the district court found that Mims had not produced evidence showing that the detectives concealed or withheld the recording from the prosecutor. The court also concluded that the recording was not material under Brady v. Maryland, and, alternatively, that the detectives were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court held that Mims failed to present evidence that the detectives intentionally or recklessly concealed the recording from the prosecution. The court emphasized that the prosecutor had knowledge of and access to the recordings through the court file and that the duty to disclose exculpatory evidence primarily rests with the prosecution. Because Mims could not show suppression by the detectives, the Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants. View "Mims v City of Chicago" on Justia Law

A prisoner at Kern Valley State Prison was involved in a disputed physical altercation with two correctional officers. The prisoner alleged that the officers used excessive force against him, while the officers claimed the prisoner initiated the altercation. After the incident, the prisoner was found guilty at a prison disciplinary hearing and later filed a pro se lawsuit under 42 U.S.C. § 1983, alleging Eighth Amendment violations. Over a year after the incident, the state charged the prisoner with battery and resisting an executive officer. The prisoner ultimately entered a nolo contendere plea to the resisting charge, expressing concern that the plea might affect his civil case.The United States District Court for the Eastern District of California initially denied the officers’ motion for judgment on the pleadings, finding that the prisoner’s nolo plea was inadmissible under Federal Rule of Evidence 410(a). However, after a change in presiding judge, the court reconsidered and granted the officers’ motion, holding that the nolo plea could be considered and that the prisoner’s civil suit was barred by Heck v. Humphrey, because success in the civil suit would necessarily imply the invalidity of the criminal conviction.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that, in a § 1983 action where the Heck bar is at issue, a plaintiff’s nolo contendere plea is inadmissible under Federal Rule of Evidence 410(a) to show that the plaintiff committed the charged crime. The court concluded that neither the plea nor statements made during the plea proceedings should have been admitted against the plaintiff in the civil case. The case was remanded for further proceedings. View "KING V. VILLEGAS" on Justia Law

The plaintiff, who worked for a bank that operated a branch inside a public high school, was terminated from her employment after she publicly criticized the local school district’s mask mandate on social media and at school events. The bank’s operation at the school was part of a partnership in which the bank provided funds and services to the school district. The plaintiff’s children attended schools in the district, and she was active in school-related activities. After a series of confrontations and a critical Facebook post about a school board member, the school superintendent communicated with the bank’s branch manager, expressing disapproval of the plaintiff’s conduct and requesting that she be barred from school property. The bank subsequently suspended and then fired the plaintiff, citing her conduct and the school’s ban.The United States District Court for the District of Minnesota granted summary judgment to all defendants, finding that the plaintiff’s First Amendment rights were not violated and that there was insufficient evidence of a conspiracy or tortious interference. The court applied the Pickering balancing test, treating the plaintiff as a government contractor, and found no actionable retaliation. It also found no evidence of a meeting of the minds between the bank and the school district, and held that the superintendent and other officials were entitled to qualified immunity.The United States Court of Appeals for the Eighth Circuit reversed in part and affirmed in part. The court held that the plaintiff was not a government employee or contractor for First Amendment purposes and was entitled to ordinary citizen protections. It found that there was sufficient evidence for a jury to decide whether the superintendent, the bank, and the branch manager retaliated against the plaintiff for protected speech, and whether the superintendent tortiously interfered with her employment. However, the court affirmed summary judgment for the school board chair and the school district, finding insufficient evidence of their direct involvement or policy liability. The case was remanded for further proceedings. View "McNeally v. HomeTown Bank" on Justia Law

A former correctional officer with the Michigan Department of Corrections was terminated after a coworker accused him of making harassing and inappropriate comments. The officer, after being served with a misconduct charge and attending a disciplinary conference with his union representative, was formally terminated in July 2019. He challenged his termination through arbitration, which concluded in December 2020 with a decision upholding his dismissal. Nearly three years later, he filed a federal lawsuit against two department officials, alleging violations of his constitutional rights under 42 U.S.C. § 1983, specifically focusing on procedural due process.The United States District Court for the Western District of Michigan initially dismissed the officer’s first complaint without prejudice for lack of prosecution after he failed to respond to a motion to dismiss. When he refiled a similar complaint, the district court dismissed it again, this time on the grounds that the claim was untimely under Michigan’s three-year statute of limitations for personal injury actions and that, except for his procedural due process claim, he had forfeited his other constitutional arguments. The court also found that his procedural due process claim failed to state a claim upon which relief could be granted.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the officer’s procedural due process claim accrued, at the latest, on the date of his post-termination arbitration hearing in December 2020, making his June 2024 complaint untimely. The court further held that Michigan law does not permit equitable tolling of the statute of limitations in this context and that the officer failed to plausibly allege inadequate process either before or after his termination. The Sixth Circuit affirmed the district court’s dismissal. View "Bozzo v. Nanasy" on Justia Law

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law